Question

Subject: Choice of Law - Lex Loci Celebrationis

Dean and Maria, both Philippine citizens, got married in the United States. They later encountered marital problems and decided to file for divorce. Dean filed for divorce in the state of Nevada, while Maria filed for divorce in the Philippines. Dean now seeks recognition of his divorce in the Philippines, while Maria seeks recognition of her divorce in Nevada.

Discuss the applicability of the doctrine of Lex Loci Celebrationis in determining the validity of Dean and Maria's respective divorces. Cite relevant laws and jurisprudence to support your answer.